Presentation on Data Protection and Governance in "cloud" computing environments delivered to students in DCU in 2011

1. ENTERPRISE
COMPUTING
A SNAPSHOT OF THE FUTURE TODAY
© 2011 Castlebridge Associates

2. Cloud
Regulation
Governance
Privacy
A New
Age
Age of the
Platform
Information
Age
Accountability
Liability
Information
Quality
Consumerisation
of IT
Emergence of
hybrid job roles
and functions
Outsourcing
Virtual
Business
Models

3. ABOUT ME
•
Studied Bachelor of Business & Legal Studies in UCD
•
CRM Programme Manager in a large telco from 2001 to 2006.
•
Regulatory Operations Programme Manager 2006 to 2009.
•
Founded Castlebridge Associates in 2009.
•
Contributed to syllabus of the European Masters in Business Informatics
•
Fellow of the Irish Computer Society
•
Founder member of the International Assoc. for Information & Data Quality,
Director of Publicity for 4 years
•
Lead Irish and UK member groups of the IAIDQ.
•
Provide consulting and training services to Government, Financial Services,
Health Care, Education and Oil & Gas distribution.
•
Constantly looking for talented and motivated people to join our network of
Associates and „back-office‟ service team.

4. SOME THOUGHTS
ABOUT CLOUD

5. Form should always
follow function
Louis Sullivan, Architect (1896)

6. Rapidly changing technology can be both a threat to this right
and the means of protecting it.
Building data protection safeguards into new technologies and
applications of these technologies remains the best approach.
This is as much true of data processing in the "cloud" as it is of a
routine development of an IT application in an organisation.

7. We both believe that companies who direct their
services to European consumers should be subject
to EU data protection laws. Otherwise, they should
not be able to do business on our internal market
Joint Statement by Viviane Reding, European Commission for Justice
and the German Consumer Protection Minister, November 2011.

8. For
Reduces barriers to entry into markets
Allows companies to scale faster/ramp
up resources more flexibly
Reduces capital requirements for startups or for businesses in expansion
phase
Against
You are using the same platform as
your competitors (reduced competitive
differentiation)
Can increase complexity of complying
with Data Protection and other
regulations
Integration of multiple data repositories
requires a plan and a strategy to avoid
redundancy and poor quality data
Outsource complexity of IT Security for
hosted data to a 3rd party.
Outsource IT Security for hosted data
to a 3rd party.
Investment in cloud means investment
for improved Information Management
practices and behaviours.
“Free lunch” syndrome.

10. THE ENTERPRISE COMPUTING
CHALLENGE:
To implement Cloud-based solutions in
ways that
1. First do no harm
2. Improve actual as well as
accounting efficiency
3. Optimise the entire system, not just
one function
4. Are appropriate to strategic intent
and business need

11. THE ENTERPRISE COMPUTING
OPPORTUNITY
Everyone is Enterprise Scale Now.

12. THE SOLUTION TO SILOS?
Silos are simple instances of IT, where processes and
data reside in their own little universe, typically not
interacting with other systems... Cloud computing will
address efficiency around resource utilization, but any
gains there could be rapidly lost if we're just using cloud
computing to build more silos.
David Linthicum, The Danger of Cloud Silos, Infoworld.com, 17th August 2010

13. ENTERPRISE SCALE SME
Integrated with
Provides
Accessed Via

14. CHALLENGE
• Integration of information the key challenge.
• Requirement for
• Efficiency
• Effectiveness
• Reliability
• Zero tolerance for double or triple entry of data across
different platforms
• “Free” cloud not always appropriate
• Cloud often provided good solutions (but not always)

15. SERVICES BEING CULLED AT/BY YEAR END
Tool
Reason
Cloud based receipts
logging tool
•
•
•
•
Google Apps
• Total Cost of Ownership for range of tools
we wanted was too high
• Data Protection Compliance concerns (don‟t
know where in world data is)
Current Hosted CRM
• Doesn‟t integrate cleanly with MS
Office/Outlook
• Requires rekeying of data or remembering to
BCC emails to a drop box to link to
opportunities etc.
Doesn‟t do what it claimed to
Cumbersome
Doesn‟t integrate with accounting package
Still need back office staff to rekey data

16. Simplicity is the
ultimate
sophistication

17. ACCOUNTABILITY
AND LIABILITY

18. CIVIL LITIGATION
• Common Law duties of care in relation to
Information
•
•
•
•
Negligent misstatement
Defamation
Injury
Medical Negligence

19. CIVIL LITIGATION
• Ferguson v British Gas [2009] EWCA Civ 46
Queries letters.
Switched from
British Gas
CRM
System
Billing
System
Credit
Management
Confirm no debt. Issue letter.
Final Bill issued & paid in full.
Confirmed with a zero balance bill.
Starts churning out automated letters
demanding payment of outstanding bill
Generates automated letters threatening legal action and referral to collections
agency. File is prepared to transfer to BG Debt Collectors

20. CIVIL LITIGATION
Court of Appeal in England & Wales
1.
Not a defence to argue that automated letters were “less
important” than ones written by individuals.
2.
Criminal offence being complained of was Harassment
3.
•
Required a “Controlling Mind”.
•
Court held that the company was the controlling mind and..
•
… would imply across that mind any relevant knowledge.
Blaming computer not accepted:
“real people are responsible for programming and entering
material into the computer. It is British Gas’s system which,
at the very least, allowed the impugned conduct to happen”

21. CIVIL LITIGATION
Leadership
Process Definition
Policies & Procedures Information Quality Communications
Data Definition
Information Security Policies Responsibility/Accountability

22. EMERGENCE OF “SELF SERVICE”
Who can access what data?
an
Who do KW‟s go to if there is a problem with the data?
What does the data actually mean ?
Where do KW‟s go to request access to data?
Who can change data? How?
How do we control the adoption of tools and
technologies?
Are we sure that the new use is consistent with
Regulatory or other obligations?
Are we comparing apples with oranges in reporting?
What is the process for bringing in new data sources?
Are we keeping aligned with Company Strategy?

23. EMERGENCE OF “SELF SERVICE”
Consumerisation of IT
Bring your (own) Computer to work
Open Source tools
Don‟t wait… DOWNLOAD!!
Cloud „Quick Fixes‟

24. Making the „plumbing‟ work consistently and
reliably in the face of environments that are not
perfectly controllable will be a big challenge in
Enterprise Computing going forward

25. TWO AGES ARRIVING

26. Age of the Platform
The Information Age

27. THE AGE OF THE PLATFORM
If the changes wrought by technology were temporary
then perhaps they could be easily dismissed as flashes in
the pan. However technology‟s march is not abating; in
fact it is intensifying. For this very reason, people need
simple, secure, powerful, integrated, and user-friendly
ways to create, consume, purchase, share, and manage
their content. They need to connect with others –easily
and often. For all these reasons they need platforms.
Phil Simon

28. WHAT IS A PLATFORM?
Scales quickly and easily
ECO SYSTEM
Partners
Users
Vendors
Customers
Feature
Feature
Feature
Stakeholders
PLANKS
Feature

29. PLATFORM COMPANY
CHARACTERISTICS
Data is portable
Presentation
Data is portable
Integration

30. EXAMPLES OF PLATFORM COMPANIES
But ANY company can build a platform using tools available today.

31. THE INFORMATION AGE
It‟s the Information,
stupid

32. INFORMATION QUALITY
In the age of platforms and Cloud, when efficiency and
success require things to work and to talk to each other
effectively, organisations will have to pay particular
attention to the quality of their information so that it is
usable in all parts of the platform with minimal scrap,
rework, and process failure.

33. GOVERNANCE
Pursuing a cloud computing strategy on
external, cloud-based virtualized servers
without a data governance strategy could
very well wreak havoc on any enterprise
Mike Ferguson, B-Eye-Network, 28/09/2009

34. Everyone is Enterprise